Brief Situation Overview
A trust examiner conducted an HST audit of The Canadian Auto
Exchange for 2013 reporting periods. As a result of the
examination, all input tax credits (ITCs) claimed by The Canadian
Auto Exchange during that period were disallowed. The CRA
reassessed and denied all the credits claimed during the
examination period in addition to all subsequent HST periods. The
analysis of the tax examiner was flawed and resulted in over
$800,000 in denied ITCs.
Toronto tax lawyers Rotfleisch & Samulovitch were hired by
the client to assist with the GST/HST appeal case.
Problems & Challenges
The Canadian Auto Exchange exports vehicles to other countries
so collecting supporting documents was challenging. The Appeals
Division at the CRA was, at times, less than reasonable with their
requests for documents and it was necessary for Toronto tax lawyers
Rotfleisch&Samulovitch to request extensions in order to meet
CRA's expectations. At one point, the CRA